Aug 13th, 2015

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE 

Washington, DC 20590

Re: Petition of City Limits Inc., dba Sky and City, for an Exemption Pursuant to Section 333 of the 

FAA Modernization and Reform Act of 2012

To Whom it May Concern:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 ("Reform Act") and 14 C.F.R. 

Part 11, Sky and City Photography LLC ("Sky and City") hereby applies for an exemption from the Federal 

Aviation Regulations ("FARs") identified below to allow commercial operation of small unmanned aerial 

vehicles (i.e., "small unmanned aircraft" or "UAS") for the purpose of conducting: aerial videography,

photography, surveying, mapping and inspection services for residential, commercial, industrial and 

government real estate property services.

This petition for exemption addresses pertinent FAA FAR’s and CFR’s as well as, but not limited to, 

these accompanying Sky and City documents.

1. PIC Flight Operations Manual and;

2. Operations Manuals"

(collectively referred to as "Sky and City' Documents & Manuals")

3. User Guide and;

4. Flight Manual

(collectively referred to as "Manufacturer's Manuals").

1

The Sky and City submits these as well as other Sky and City supporting materials as 

confidential documents pursuant to 14 C.F.R. § 11.35 (b), as the materials contain confidential 

commercial and/or proprietary information that the Sky and City has not and will not share with others. 

Additionally, these documents contain operating conditions and procedures that are not generally

available to the public and are protected from release under the Freedom of Information Act, 5 U.S.C. § 

552 et seq.

1The term "Manufacturer's Manual" also includes all relevant manufacturer publications, including, but not 

limited to: operations and flight manuals, user guides, component maintenance manuals, pilot training 

manuals, service information letters and, safety/service bulletins).
U.S. Department of Transportation

Aug 13th, 2015

Page 2

This Petition is organized as follows:

I. Petitioner

II. Description of Proposed Operations

A. Real Estate Aerial Photography, Videography, Mapping and Inspection Services

III. Relevant Statutory Authority

IV. Sky and City’s Proposed SC-UAS Operations Meet the Requirements of Section 333 of the

Reform Act

A. Approval is Warranted Based on the SC-UAS's Size, Weight, Speed, and Operational Capability

B. Approval is Warranted Based on the Operational Restrictions Set Forth in the Operations

Manuals

V. Regulations From Which Exemption is Requested

A. 14 C.F.R. Part 21, Subpart H – Airworthiness Certificates and 14 C.F.R. § 91.203(a)(1) 

B. 14 C.F.R. Part 27 Airworthiness Standards: Normal Category Rotorcraft

C.14 C.F.R. §§ 91.9(c), 45.23(b) and 45.27(a): Aircraft Marking and Identification Requirements

D. 14 C.F.R. § 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2); 91.417(a) and (b): Maintenance Inspections

E. 14 C.F.R. Part 61, 14 C.F.R. § 61.3, 14 C.F.R. § 61.113: Private Pilot Privileges and Limitations

F. 14 C.F.R. § 91.7(a): Civil Aircraft Airworthiness

G. 14 C.F.R. § 91.9(b)(2): Civil Aircraft Flight Manual in the Aircraft and 14 C.F.R. § 91.203(a) and (b): 

Carrying Civil Aircraft Certification and Registration

H. 14 C.F.R. § 91.103: Preflight Action

I. 14 C.F.R. § 91.109(a): Flight Instruction

J. 14 C.F.R. § 91.119(c): Minimum Safe Altitudes

K. 14 C.F.R. § 91.121: Altimeter Settings

L. 14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions

VI. Drug and Alcohol Program

VII. Public Interest

VIII. Privacy

IX. Federal Register Summary

X. Conclusion
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Aug 13th, 2015

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I. DESCRIPTION OF PETITIONER

Based in Pacoima, CA, Sky and City, in partnership with City Limits Inc., will begin offering unique real 

estate property aerial video, photography, surveying, mapping and inspection services. Plans are to specialize

in high altitude photography, videography, etc, by the use of traditional aircraft, and will offer low altitude 

photography, videography, etc, through the commercial deployment of UAS. 

City Limits Inc., and its founder’s share in more than 30 years of flight experience that span multiple 

industries providing exclusive services for many of the world's most respected leading media organizations 

including; CNN, NBC, HLN, AEG Live, Interscope, Capitol Records. Additionally, the company has board 

seats and participates in various nonprofit organizations such as the Boys & Girls Club and Angel Flight. City 

Limits is a highly respected premier design leader having been nominated for several awards and earning; a 

Peabody Award and a Columbia Du-Pont Award. 

City Limits Inc. and Sky and City’s mission is to utilize the latest technology and bring this unique real estate

property service to a wider audience at a lower cost focusing on quality real estate property, landscape design 

and new innovative construction services.

Providing a menu of high level skilled offerings to current and new clients, and by implementing the use of 

the latest UAV video and mapping technologies, City Limits Inc., and Sky and City are in a unique position to 

provide a new and valuable service to an audience of private and business clients. Such technology offerings 

have not previously been offered by any company or person. Sky and City seek an exemption to allow the 

company to commence as soon as possible commercial operations of small UAS to provide aerial videography,

photography, surveying, mapping and inspection services for residential, commercial, industrial and 

government real estate property services.

The contact information for Petitioner is as follows: 

Carll Alvarado

City Limits, Inc.

12653 Osborne Street

Pacoima, CA, 91331

Phone: (718)-213-3069

Email: dezalvarado@gmail.com

II.DESCRIPTION OF PROPOSED OPERATION

Sky and City seeks an exemption pursuant to Section 333 of the Reform Act to operate the DJI Inspire 

1 (SC-UAS) for the proposed operations discussed below. UAS operations will occur under tightly

controlled conditions on private property where Sky and City has received permission to operate from the

landowner, controller or authorized representatives. The proposed UAS operations will be conducted in 

accordance with the conditions and limitations of this Petition for Exemption and Sky and City’s Operations 

Manuals. As detailed in Sky and City’s Operations Manuals, all UAS operations will be limited to daytime

VFR conditions, within visual line-of-sight ("VLOS") of the operator, in uncontrolled airspace, and will

occur at least 5 nm away from an airport. Moreover, Sky and City’s Operations Manuals incorporate 

redundant safeguards to assure that the aircraft does not travel outside the controlled area of UAS operations, 

including GPS "geo-fencing" technologies.
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Aug 13th, 2015

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A. Real Estate Aerial Videography. Photography, Mapping and Inspection Services

Sky and City seeks to use small SC-UASs for the purpose of conducting aerial videography, 

photography and inspection of real estate property.

Sky and City has tailored its operations to meet the requirements established by the FAA in prior grants of 

exemptions authorizing commercial use of SC-UAS in the aerial videography, photography and 

inspection of real estate industry, including:

 Trudeau, Realtor® (Exemption No. 11138);

 Alon Sicherman (Exemption No. 11728);

 Sokoler Medley (Exemption No. 11341);

SC-UAS seeks to use small UASs for the purpose of conducting aerial videography, photography and 

inspection of real estate property operations. Such work will be conducted on private property in a

controlled area, away from spectators and persons not involved in the aerial videography, photography and 

inspection of real estate property. SC-UAS video and inspection work will be conducted during daylight 

hours, VFR conditions, at altitudes below 400' AGL. As set forth below, Sky and City’s operations provide 

a superior level of safety and quality compared to performing the same video work using conventional

fixed-wing aircraft or helicopters.

The proposed SC-UAS operations in this Petition for Exemption significantly improves safety and 

reduces risk, harm or serious injury to real estate inspectors and property assessors. Traditional methods of 

real estate video production and inspection of structures, expose videographer-inspectors to higher risks of 

serious injuries, or death. Videographer-inspectors need to climb roof tops or otherwise perform elevated 

work, which exposes them to the risk of dangerous falls, electrocution or other work related extremes. In 

addition, depending on the nature of the video needed and the inspection work, proximity to equipment and 

other hazards associated with industrial real estate sites and real estate construction locations often involves a 

great deal of risk to accomplish the job. The use of SC-UAS mitigates these hazards and is ultimately a much 

safer method of performing these and most other types of inspections.

SC-UAS real estate video production and inspection of structures is much safer than traditional 

manned aircraft performing the same function. Conventional operations using rotorcraft and fixed-wing 

aircraft in low level operations present very high risks with vehicles weighing thousands of pounds, carrying

passengers and large amounts of fuel. It is important to note that the use of small SC-UAS in this area will

not only be safer and more cost effective, but the quality of collected data and information is far superior.

SC-UAS real estate video production and inspection of structures is more reliable, and allows for the 

collection, dissemination, and storage of visual content and other sensory data with greater precision and 

duration. SC-UASs are also capable of accessing finish and structural quality through the use of video and 

inspecting areas that would otherwise be inaccessible to humans and would be impossible to be completed 

with conventional aircraft or other inspection methods.
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Aug 13th, 2015

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IV. RELEVANT STATUTORY AUTHORITY

This Petition for Exemption is submitted pursuant to Section 333(a) through (c) of the FAA 

Modernization and Reform Act of 2012 ("Reform Act"). Congress has directed the FAA "to safely 

accelerate the integration of civil unmanned aircraft systems into the national airspace system." Pursuant to 

Section 333 of the Reform Act, the FAA Administrator is to permit unmanned aircraft systems to operate in 

the National Air Space ("NAS") where it is safe to do so based on the following considerations:

● The UAS's size, weight, speed and operational capability;

● Operation of the UAS in close proximity to airports and populated areas; and

● Operation of the UAS within the visual line of sight of the operator.

Additionally, the FAA Administrator has general authority to grant exemptions from the agency's 

safety regulations and minimum standards when the Administrator decides a requested exemption is in the 

public interest. See 49 U.S.C. § 106(f) (defining the authority of the Administrator); 49 U.S.C. § 44701(f) 

(permitting exemptions from §§ 44701(a), (b) and §§ 44702 – 44716, et seq.). A party requesting an 

exemption must explain the reasons why the exemption: (1) would benefit the public as a whole, and (2) 

would not adversely affect safety (or how it would provide a level of safety at least equal to the existing 

rules). See 14 C.F.R. § 11.81 (petitions for exemption).

IV. HIGHER UP'S PROPOSED UAS OPERATIONS MEET THE REQUIREMENTS OF

SECTION 333 OF THE REFORM ACT

The SC-UAS operations proposed by Sky and City in this Petition for Exemption qualify for 

expedited approval pursuant to Section 333 of the Reform Act as each of the statutory criteria and relevant 

factors are satisfied.

A. Approval is Warranted Based on the SC-UAS's Size, Weight, Speed, and Operational

Capability

A Grant of Exemption is appropriate for operations conducted using the SC-UASs due to its size weight, 

speed, and operational capability.
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Aug 13th, 2015

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o The SC-UAS models have been approved for use in prior Section 333 Grants of Exemption from the

FAA.

2

o The SC-UAS models weighs less than 55 pounds, including payload.

o The SC-UAS will not be flown at a ground speed in excess of 50 knots.

o Altitude information will be generated by equipment onboard the UA as specified using GPS 

triangulation, digitally encoded barometric altimeter, radio altimeter, or any combination thereof. 

This information will be transmitted to the pilot via telemetric data feed.

o The SC-UASs will have system redundancies and independent functionality to ensure the overall 

safety and predictability of the system. If connection to the remote control or ground control station 

is lost, failsafe systems will permit the SC-UAS to return to a predetermined location and safely 

land without injury or damage.

o The radio frequencies used for operations and control of the SC-UAS comply with the Federal 

Communications Commission ("FCC") and other appropriate government oversight agency 

requirements. The operating frequency for the SC-UAS are 2.4 GHz.

If the same operations were conducted using a helicopter, the aircraft's take-off weight would likely exceed

6,000 pounds carrying a pilot, camera operator and VO-visual observer- navigator. The difference in 

weight between the SC-UAS and a helicopter significantly reduces the potential harm to the participating 

and non-participating individuals or property in the event of an accident or incident. In addition, the risk to

the onboard pilot and camera operator is eliminated.

2

See e.g., Grant of Exemption to Shotover Camera Systems L.P. (Exemption No. 11159); Grant of 

Exemption to VDOS Global, LLC (Exemption No. 11112); Grant of Exemption to Low Country RC, Corp. 

(Exemption No. 11184); Grant of Exemption to Alan Purwin (Exemption No. 11161); Grant of Exemption 

to Helinet Aviation Services (Exemption No. 11160); Grant of Exemption to Total Safety U.S., Inc. 

(Exemption No. 11156).
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Aug 13th, 2015

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B. Approval is Warranted Based on the Operational Restrictions Set Forth in Sky and City’s

Operations Manuals

Sky and City’s Operations Manuals and the Manufacturer's Manual for the selected SC-UASs will 

contain all the procedures and limitations necessary to safely and successfully perform the operations 

specified in this Petition for Exemption. To assist the FAA in making a safety assessment of Sky and 

City’s proposed operations, below is a summary of operational limitations and conditions that Sky and 

City will adhere to, and which will ensure an equivalent or higher level of safety to operations conducted 

under current regulatory guidelines:

1. The SC-UAS weighs less than 55 pounds, fully loaded.

2. All operations shall be conducted over private or controlled-access property with permission from 

the land owner/controller or authorized representative. Permission from land owner/controller or 

authorized representative will be obtained for each flight operation.

3. All SC-UASs operated under the Grant of Exemption will be identified by serial number, 

registered in accordance with 14 CFR part 47, and have identification (N-Number) markings in 

accordance with 14 CFR part 45, Subpart C. Markings will be as large as practicable.

4. Minimum crew for each flight operation will consist of a pilot, who will be Pilot- in Command 

("PIC") of the SC-UAS, and one or more Visual Observers ("Observer") as necessary to safely 

conduct the mission.

5. PICs shall possess at least a Private Pilot's Certificate and current Class III Medical Certificate. The 

PIC will also meet the flight review requirements specified in 14 C.F.R 61.56 in an aircraft in which 

the PIC is rated on his or her pilot certificate.

6. The UA shall be operated within VLOS of the PIC and Observer at all times. The PIC must use 

human vision unaided by any device other than corrective lenses, as specified on the PIC's FAAissued medical certificate.

7. The PIC and Observer designated for any operation will be able to communicate verbally at all 

times.

8. Electronic messaging or texting will not be permitted during flight operations.

9. The additional requirements identified in the Grant of Exemption shall be added to the Sky and City’s

Operations Manuals.
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Aug 13th, 2015

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The Operations Manuals will be maintained and made available to the Administrator upon request. If a 

discrepancy exists between the conditions and limitations in the Grant of Exemption and Sky and City’s 

Operations Manuals, the conditions and limitations in the Grant of Exemption shall take precedence and 

must be followed. Otherwise, Sky and City shall follow the procedures outlined in their Operations 

Manuals.

10. Sky and City may update or revise its Operations Manuals. Revisions will be tracked and a

revised copy of the Manual will be provided to the Administrator upon request.

Sky and City will also present an updated and revised Operations Manuals if it petitions for extension or 

amendment to its Grant of Exemption. If an update or revision would affect the basis upon which the FAA 

grants the exemption, Sky and City will seek an amendment to its Grant of Exemption. Sky and City will 

contact the FAA’s SC-UAS Integration Office (AFS-80) if questions arise regarding updates or revisions 

to the operating documents.

11. Sky and City’s Operations Manuals and its Grant of Exemption will be available to the

PIC at the ground control station anytime the SC-UAS is operating.

12. The PIC is prohibited from beginning a SC-UAS flight unless (considering wind and forecast 

weather conditions) there is enough power to fly to the first intended point of landing, and assuming normal 

cruising speed, to fly after that for at least 10 minutes.

13. Maximum total flight time for each operational flight using the SC-UAS will be limited to 40 

minutes or the amount of time the SC-UAS can be flown and still maintain a reserve battery power of no 

less than 25%, whichever occurs first.

14. Flights will be operated at an altitude of no more than 400 feet AGL and will never enter navigable 

controlled airspace without prior written authorization and approval from the FAA. In the event the 

structure being inspected exceeds 400 feet AGL, the SC-UAS will not be operated more than 100 feet 

above the highest point on the structure, and no more than 100 feet horizontally from the structure.

15. Flight operations must be conducted at least 500 feet from all nonparticipating persons. (persons 

other than the PIC, VO, operator trainees or essential personnel), vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating persons from the UA

and/or debris in the event of an accident. The operator must ensure that nonparticipating

persons remain under such protection. If a situation arises where nonparticipating persons leave 

such protection and are within 500 feet of the UA, flight operations must cease immediately 

and/or;
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Aug 13th, 2015

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b. The aircraft is operated near vessels, vehicles or structures where the owner/controller of such 

vessels, vehicles or structures has granted permission and the PIC has made a safety assessment 

of the risk of operating closer to those objects and determined that it does not present an undue 

hazard, and;

c. Operations nearer to the PIC, VO, operator trainees or essential persons do not present an 

undue hazard to those persons per § 91.119(a).

16. The UA may not be operated less than 500 feet below or less than 2,000 feet horizontally from a 

cloud or when visibility is less than 3 statute miles from the PIC.

17. The UA may not operate within 5 nm of an airport reference point as denoted on a current FAApublished aeronautical chart unless a letter of agreement with that airport’s management is obtained, and

the operation is conducted in accordance with a NOTAM as required by the Sky and City COA. The letter 

of agreement with the airport management will be made available to the Administrator upon request.

18. Prior to each flight the PIC shall inspect the SC-UAS to confirm that it is in a condition safe for 

flight. The pre-flight inspection will account for all discrepancies, e.g. inoperable components, items, or 

equipment, not already covered in the relevant sections of the operating documents. The PIC shall not 

operate the SC-UAS if the inspection reveals a condition that affects the safe operation of the SC-UAS until 

the necessary maintenance has been performed and the SC-UAS is found to be in a condition for safe flight. 

The ground control station shall be included in the preflight inspection. All maintenance and alternations 

must be properly documented in the SC-UAS records as required by Sky and City’s Operations Manuals.

19. Sky and City will carry out its maintenance, inspections, and record keeping requirements in 

accordance with the Operations Manuals. Maintenance, inspection, and alterations will be noted in the 

SC-UAS records, including total time in service, description of work accomplished, and the signature of 

the authorized person returning the SC-UAS to service.

20. Any SC-UAS that has undergone maintenance or alterations that affect the SC-UAS operation

or flight characteristics (e.g., replacement of a flight critical component) must undergo a functional test 

flight in accordance with Sky and City Operations Manuals. The PIC who conductsthe functional test

flight must make an entry in the SC-UAS aircraft records of the flight. The requirements and proceduresfor a

functional test flight and SC-UAS record entry shall be included in the Sky and City’ Operations 

Manuals.
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Aug 13th, 2015

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21. The SC-UAS will be operated and maintained according to the Manufacturer's Manuals and any 

required manufacturer Safety/Service Bulletins.

22. Prior to the operation, a Mission Packet will be created in accordance with the requirements on

Sky and City’s Operations Manuals.

23. Sky and City will obtain an Air Traffic Organization ("ATO") issued Certificate of Waiver or 

Authorization, otherwise known as a COA, prior to conducting any operations under this Grant of 

Exemption. A NOTAM will be issued as required by the COA. All operations will be conducted in 

accordance with airspace requirements in the ATO issued COA including class of airspace, altitude level 

and potential transponder requirements.

24. All required permissions and permits will be obtained from territorial, state, county or city 

jurisdictions, including local law enforcement, fire or other appropriate governmental agencies

25. If the SC-UAS loses communication with the pilot, it will have the capability to return to a predetermined location within the operational area and land safely.

26. Contingency plans will be in place to safely terminate flight if there is a loss of communication 

between the PIC and the Observer.

27. The SC-UAS will have the capability to safely abort flight in the case of unpredicted obstacles or 

emergencies.

28. PICs and Observers will have at least a current Class III Medical Certificate.

29. Prior to conducting operations for filming, the PIC will have accumulated and logged, in a manner 

consistent with 14 CFR § 61.51(b), a minimum of 200 flight cycles and 25 hours total time as a SC-UAS

rotorcraft pilot and at least 10 hours logged as a SC-UAS pilot with a similar SC-UAS type.

30. Prior to conducting operations for filming, the PIC will have accumulated and logged, in a manner 

consistent with 14 CFR § 61.51(b), a minimum of 54 CFR §61.51(b), a minimum of 10 logged hours as 

SC-UAS pilot operating the make and model of SC-UAS to be utilized for operations under the exemption 

and thirty take-offs and thirty landing in the preceding 90 days.
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Aug 13th, 2015

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31. Operations shall occur during daytime VFR Meteorological Conditions; flights under Special

Visual Flight Rules ("SVFR") shall not be conducted.

32. The UA shall remain clear and yield the right of way to all other manned operations and activities 

at all times (including, but not limited to, ultralight vehicles, parachute activities, parasailing activities, 

hang gliders, etc.).

33. SC-UAS Operations under Instrument Flight Rules, at night, or beyond VLOS are prohibited.

34. The SC-UAS will not be operated from an elevated platform or moving device / vehicle.

35. Before conducting operations, the radio frequency spectrum used for operation and control of the 

UA will comply with the Federal Communications Commission (FCC) or other appropriate government 

oversight agency requirements.

V. REGULATIONS FROM WHICH EXEMPTION IS REQUESTED

The Federal Aviation Act expressly grants the FAA the authority to issue exemptions. This statutory 

authority, by its terms, includes exempting civil aircraft, as the term is defined under § 40101 of the Act, 

including SC-UASs, from its safety regulations and minimum standards when the Administrator decides a 

requested exemption is in the public interest.

3

Sky and City seeks an exemption from several interrelated provisions of Title 14 of the Code of

Federal Regulations ("14 C.F.R") Parts 21, 45, 61 and 91 for purposes of conducting the requested operations 

using a SC-UAS. Listed below are: (1) the specific sections of 14 C.F.R for which exemption is sought, and 

(2) the operating procedures and safeguards that Petitioner has established which will ensure a level of safety

better than or equal to the rules from which exemption is sought.4

3

49 U.S.C. § 44701(f) (authorizing the grant of exemptions from requirements of regulations prescribed 

pursuant to Sections 44701(a) and (b) and Sections 44702 - 44716).

4

14 C.F.R § 11.81(e), which requires a petition for exemption to include:

The reasons why granting the exemption would not adversely affect safety, or how the exemption would 

provide a level of safety at least equal to that provided by the rule from which you seek exemption.
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th, 2015

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UNMANNED AIRCRAFT SYSTEM

A. 14 C.F.R. Part 21, Subpart H – Airworthiness Certificates and 14 C.F.R. § 91.203(a)(1)

The FAA has stated that no exemption is needed from this section if a finding is made under the 

Reform Act that the SC-UAS selected provides an equivalent level of safety when compared to aircraft 

normally used for the same application. These criteria are met, and therefore no exemption is needed.

5 If, 

however, the FAA determines that there are some characteristics of the chosen SC-UAS that fail to meet the 

requirements of the Reform Act, an exemption is requested.

Equivalent Level of Safety

Sky and City’s use of the SC-UAS is safe when taking into account their size, weight, speed, and 

operational capability. As set forth in the description of proposed operations in Section IV (A), the 

SC-UAS weighs less than 55 pounds, including payload and will not be flown at a ground speed in 

excess of 50 knots. SC-UAS is also equipped with safety features that will allow Petitioner to 

operate the SC-UAS safely after experience certain in-flight contingencies or failures.

6 7

5

See Grant of Exemption No. 11062 to Astraeus Aerial (FAA-2014-0352 at pgs. 13-14, 22).

6

See e.g., Grant of Exemption No. 11184 to Low Country RC, Corp. (FAA-2014-0803 at pg. 3):

"The [SC-UAS] has the capability to operate safely after experiencing certain in-flight contingencies or 

failures and uses an auto-pilot system to maintain SC-UAS stability and control. The SC-UAS is also able

to respond to a loss of global positioning system (GPS) or a lost-link event with a pre-coordinated, 

predictable, automated flight maneuver, and manual flight control functionality as a backup. These safety 

features provide an equivalent level of safety compared to a manned aircraft performing a similar 

operation."

7

See e.g., Grant of Exemption No. 11184 to VDOS Global, LLC. (FAA-2014-0382 at pgs. 4-5):

"The SC-UAS with its upgrade can be operated entirely by a touch-screen, map-based interface. This means

the operator only needs to command the system where to go, and the system does all the flying for the 

operator. The SC-UAS can be operated in both semi and fully autonomous flight modes, with the operator

simply clicking on a map to create a pre-planned flight path for a flight. In addition, the operator can create no 

fly zones or maximum flight ranges and altitudes so the system cannot enter areas deemed unsafe or

unnecessary to fly over. The petitioner states further that the SC-UAS has built-in intelligent fault handling

which allowsthe SC-UAS to detect a system fault while in the air and automatically fly back to its takeoff

location and land. Faults that can be detected include: loss of communication; exceeding pre-set

wind thresholds; and low battery levels.

{footnote continued}
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Additionally, the SC-UASs carry neither pilots nor passengers, carry no explosive materials or 

flammable liquid fuels, and operate exclusively within the parameters stated in the Sky and 

City's Operations Manuals.

Operations conducted under this exemption will be closely controlled and monitored by the operator 

and will be conducted in compliance with local public safety requirements, to provide security for the area of 

operation. Sky and City will also provide the FAA with advance notice of all operations via NOTAMs as 

required by the applicable COA. In all cases, operation of the SC-UAS under the proposed conditions will 

be at least as safe as, or safer than, conventional rotorcraft operating with an airworthiness certificate.

Lastly, the SC-UASs do not need a means to communicate with other aircraft or ATC, because those

capabilities will be possessed by the PIC and Observer, who are not onboard the SC-UAS.

8 In addition, no 

sense-and-avoid technology is necessary for the SC-UASs because they will be operated at all times in VFR

conditions and within VLOS of the PIC and Operator.

9

B. 14 C.F.R. Part 27 Airworthiness Standards: Normal Category Rotorcraft

Title 14 C.F.R. Part 27 sets forth the procedural requirements for airworthiness certification of normal 

category rotorcraft. To the extent that the Sky and City's small SC-UASs would otherwise require 

certification under Part 27, Petitioner seeks an exemption from Part 27's airworthiness standards for the same 

reasons identified in the request for exemption from 14 C.F.R. Part 21, Subpart H, supra.

{continued from previous page}

7

See e.g., Grant of Exemption No. 11184 to VDOS Global, LLC. (FAA-2014-0382 at pgs. 4-5):

All flight operations are global positioning system (GPS) controlled, making the system easy to 

navigate. At any point if the operator is not explicitly commanding the system to move, the system 

automatically holds its GPS position. The flight control system employs not only GPS positioning but 

a variety of sensors including sonar, barometric pressure, temperature, wind speed and others to ensure 

stability so long as wind thresholds are not exceeded. Also a flight termination link – to prevent a 'fly 

away' or other potentially dangerous situation – is available to the operator."

8

See Grant of Exemption No. 11062 to Astraeus Aerial (FAA-2014-0352 at pg. 13).

9

Id.
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C. 14 C.F.R. §§ 91.9(c), 45.23(b) and 45.27(a): Aircraft Marking and Identification Requirements

Sky and City seeks an exemption from the aircraft marking and identification requirements contained

in

14 C.F.R. §§ 91.9(c), 45.23(b) and 45.27(a).

● 14 C.F.R. § 91.9(c), Civil Aircraft Flight Manual, Marking and Placard requirements, provides that: 

No person may operate a U.S.-registered civil aircraft unless that aircraft is identified in

accordance with Part 45 of this chapter.

● 14 C.F.R. § 45.23(b), Markings of the Aircraft, states:

When marks include only the Roman capital letter "N" and the registration number is 

displayed on limited, restricted or light-sport category aircraft or experimental or 

provisionally certificated aircraft, the operator must also display on that aircraft near each 

entrance to the cabin, cockpit, or pilot station, in letters not less than 2 inches nor more

than 6 inches high, the words "limited," "restricted," "light-sport, "experimental," or

"provisional," as applicable.

● 14 C.F.R. § 45.27(a), Rotorcraft, states:

Each operator of a rotorcraft must display on that rotorcraft horizontally on both surfaces of 

the cabin, fuselage, boom, or tail the marks required by § 45.23.

In a previous Grant of Exemption, the FAA determined that exemption from these requirements was 

warranted provided that the aircraft "have identification (N-Number) markings in accordance with 14 C.F.R 

Part 45, Subpart C if the markings are as large as practicable."

10

Equivalent Level of Safety

All UA flown by Sky and City will bear N-number markings that are as large as practicable

in accordance with 14 C.F.R. Part 45, Subpart C.

11

10 FAA Docket No. FAA-2014-0352.

11See, e.g., FAA Docket No. FAA-2014-0352, at 14.
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D. 14 C.F.R. § 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2); 91.417(a) and (b): Maintenance

Inspections

Sky and City seeks an exemption from the maintenance inspection requirements contained in

14 C.F.R. § 91.405(a), 91.407(a)(1), 91.409(a)(2); 91.417(a) and (b). These regulations specify maintenance 

and inspection standards in reference to 14 C.F.R. Part 43. See, e.g., 14 C.F.R. § 91.405(a) (stating that each 

owner or operator of an aircraft "shall have the aircraft inspected as prescribed in subpart E of this part and 

shall between required inspections have discrepancies repaired as prescribed in part 43 of this chapter"). An 

exemption from these regulations is needed because Part 43 and these sections only apply to aircraft with an 

airworthiness certificate, which the SC-UAS to be operated under this grant of exemption will not have.

Equivalent Level of Safety

An equivalent level of safety will be achieved because maintenance and inspections will be performed 

in accordance with the Manufacturer's Manual and any required manufacturer Safety or Service Bulletins. 

Further, as required by Sky and City’s Operations Manuals, the PIC will conduct a pre-flight inspection of 

the SC-UAS and all associated equipment to account for all discrepancies and/or inoperable components. 

Maintenance will be performed and verified to address any conditions potentially affecting safe operation of 

the SC-UAS and no flights will occur unless, and until, all flight critical components of the SC-UAS have 

been found to be airworthy and in a condition safe for operation. A functional test flight will be conducted 

following the replacement of any flight-critical components. As required by Sky and City’s Operations 

Manuals, the PIC who conducts the functional test flight will make an entry in the SC-UAS aircraft records of 

the flight.

Sky and City’s Operations Manual also includes requirements to follow the manufacturer’s SC-UAS

aircraft/component, maintenance, overhaul, replacement, inspection, and life limit requirements for the 

following applicable components: powertrain system (powerplant), propellers, avionics and control surfaces 

(including ailerons/elevons), structures & airframe, camera system, electrical systems (including batteries), 

ground control station, hazard accessories, and spare parts. Further, Sky and City’s Operations Manuals also 

includes procedures to document and maintain a record of the SC-UAS maintenance, preventative 

maintenance, alterations, status of replacement /overhaul component parts, and the total time in service of the 

SC-UASs used under this Grant of Exemption. As a whole, the maintenance and inspection procedures 

required in Sky and City’s Operations Manuals ensure that an equivalent or higher level of safety will be 

achieved.
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PILOT-IN-COMMAND OF THE SC-UAS

E. 14 C.F.R. § 61.113: Private Pilot Privileges and Limitations

Sky and City seeks exemption from 14 CFR § 61.113, which restricts private pilot certificate holders 

from flying aircraft for compensation or hire, and would also require a second class medical certificate. The 

purpose of Part 61 is to ensure that the skill and competency of any PIC matches the airspace in which the

PIC will be operating, as well as requiring certifications if the private pilot is carrying passengers or cargo for 

hire. In this case, while the SC-UASs will be operated as part of a commercial operation, it carries neither 

passengers nor cargo.

In the Grant of Exemption to Astraeus Aerial

12, the FAA determined that the unique characteristics of 

SC-UAS operation outside of controlled airspace did not warrant the addition cost and restrictions attendant 

with requiring a the PIC to have a Commercial Pilot Certificate and Class II Medical Certificate. The 

fulfillment of the additional requirements for a private pilot to become qualified as a commercial pilot would 

not lead to any additional safety benefits when SC-UAS operations are involved.

Equivalent Level of Safety

The restrictions the Sky and City has placed on its SC-UAS operations meet or exceed the

restrictions similarly imposed on Astraeus Aerial. Sky and City will operate on private property away from 

persons and property not involved in the operation. Sky and City will also obtain an ATO issued COA prior

to conducting any operations under this Grant of Exemption. All operations will be conducted in accordance

with airspace requirements in the ATO issued COA including class of airspace, altitude level and potential 

transponder requirements. A NOTAM will also be issued as required by the applicable COA.

In addition to these flight restrictions, the Sky and City will further ensure safe operation by requiring 

that any PIC be thoroughly versed not only in airspace and communication issues pertaining to all aircraft 

operators but also in the unique aspects of SC-UAS flight. As set forth in the Operations Manuals, pilots will

have experience not only in SC-UAS operations generally but have logged flight time in the specific make

and model used for the operations before they are permitted to participate in commercial flights on behalf of

Sky and City. The pilot qualification, training, and currency requirements in the Operations Manuals ensure

that Sky and City’s pilots are competent and proficient in the SC-UAS they are operating. Sky and City’s 

training and qualification requirements are consistent with those contained in prior FAA Section 333 Grants 

of Exemption, and will provide a higher level of competency and proficiency for its pilots and will ensure at 

least an equivalent level of safety.

12 Exemption No. 11062 (FAA Docket No. FAA-2014-0352).
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OPERATING PARAMETERS OF THE SC-UAS

F. 14 C.F.R. § 91.7(a): Civil Aircraft Airworthiness

Although there will be no airworthiness certificate issued for the SC-UASs, Sky and City seeks an 

exemption from 14 C.F.R. § 91.7(a), which requires that a civil aircraft be in airworthy condition to be 

operated. The FAA has stated that no exemption is required for 14 C.F.R. § 91.7(a) to the extent that the 

requirements of Part 21 are waived or found inapplicable.

13 Accordingly, Petitioner requests that the 

requirements for § 91.7(a) be treated in accordance with Section V (A), supra.

G. 14 C.F.R. § 91.9(b)(2): Civil Aircraft Flight Manual in the Aircraft and 14

C.F.R. § 91.203(a) and (b): Carrying Civil Aircraft Certification and Registration

Title 14 C.F.R. § 91.9(b)(2) and § 91.203(a) and (b) require the operator to carry airworthiness 

documents and other aircraft manuals onboard the aircraft. Pursuant to 14 C.F.R. § 91.9(b)(2):

(b) No person may operate a U.S.-registered civil aircraft –

(2) For which an Airplane or Rotorcraft Flight Manual is required by § 21.5 of this chapter, unless 

there is available in the aircraft a current approved Airplane or Rotorcraft Flight Manual, approved 

manual material, markings, and placards, or any combination thereof.

Pursuant to 14 C.F.R. § 91.203(a) and (b):

(a) Except as provided in § 91.715, no person may operate a civil aircraft unless it has within it the 

following:

(1) An appropriate and current airworthiness certificate...

(b) No person may operate a civil aircraft unless the airworthiness certificate required by paragraph 

(a) of this section or a special flight authorization issued under § 91.715 is displayed at the cabin or 

cockpit entrance so that it is legible to passengers or crew.

13 See id. at 13-14, 22
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Page 18

Given the small size and configuration of the SC-UASs, it would be impossible to keep 

airworthiness documents and other aircraft manuals on board the SC-UAS because there is simply no 

room and the SC-UAS has no cabin or cockpit.

Equivalent Level of Safety

In an FAA Office of Chief Counsel's Opinion dated August 8, 2014, and prepared by Dean E. 

Griffith, Attorney, AGC-220, it was acknowledged that the intent of 14 C.F.R. 91.9(b) and 91.203(a) and 

(b) is met if the pilot of the unmanned aircraft has access to the SC-UAS flight manual, registration 

certificate, and other required documents from the ground control station from which he or she is operating 

the aircraft.

14 As this FAA Office of Chief Counsel Opinion clarifies, the intent of the rule is to ensure the 

pilot has access to these key documents during flight. Therefore, an equivalent level of safety will be 

achieved by ensuring that the pilot has access to the documents at the ground control station from which he 

or she is piloting the SC-UAS.

H. 14 C.F.R. § 91.103: Preflight Action

Sky and City seeks an exemption from 14 C.F.R. § 91.103, which requires a PIC to become familiar 

with specific information before each flight, including information contained in the FAA-approved Flight 

Manual on board the aircraft. While the PIC will be familiar with all information necessary to safely 

conduct the flight, an exemption is requested to the extent that an FAA-approved Flight Manual is required.

Equivalent Level of Safety

An equivalent level of safety will be provided by following the Sky and City’s Operations Manuals 

and the Manufacturer's Manual. The PIC will perform a series of checklists designed to identify any 

defects or inoperable components in accordance with the Sky and City’s Operations Manuals, including 

checklists covering Pre-Flight, Launch, Landing, and Post-Flight procedures. The PIC will also be required 

to review weather, flight requirements, battery charge, landing and takeoff distance, UA performance data, 

and contingency landing areas—before initiation of flight. Sky and City’s Operations Manuals and the 

Manufacturer's Manual will be kept at the ground control station and will be accessible to the PIC at all 

times while operating the SC-UAS.

I. 14 C.F.R. § 91.109(a): Flight Instruction

14 Memorandum from Mark Bury, FAA Assistant Chief Counsel for International Law, Legislation and

Regulation, to John Duncan, FAA Flight Standards Service (Aug. 8, 2014); see also Docket No. FAA2014-0352 at 16-18.
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Page 19

Sky and City seeks an exemption from 14 C.F.R. § 91.109(a), which provides in pertinent part that 

"[n]o person may operate a civil aircraft (except a manned free balloon) that is being used for flight 

instruction unless that aircraft has fully functioning dual controls." SC-UASs and remotely piloted aircraft, 

by their design, do not have functional dual controls. Instead, flight control is accomplished through the

use of a device that communicates with the aircraft via radio communications. Accordingly, an exemption 

will be required for the flight instruction requirements of 14 C.F.R. § 91.109(a).

Equivalent Level of Safety

Given the size and speed of the SC-UASs that Sky and City intends to use, an equivalent level of 

safe training can still be performed without dual controls because no pilot or passengers are aboard the 

SC-UAS, and as required by the Sky and City’s Operations Manuals, all persons will be a safe distance 

away in the event that the SC-UAS experiences any difficulties during flight instruction. Moreover, as 

required by the Sky and City’s Operations Manuals, all flight training will be conducted in controlled 

and sterile environment. As a whole, the safety procedures provided for in the Sky and City’s 

Operations Manuals ensure that the proposed SC-UAS operations provide an equivalent or higher level 

of safety than that provided by the flight instruction regulations.

J. 14 C.F.R. § 91.119(c): Minimum Safe Altitudes

The Sky and City requests an exemption from the minimum safe altitude requirements of 14 C.F.R. §

91.119(c).

15 Section 91.119 prescribes the minimum safe altitudes under which aircraft may not operate, 

including 500 feet above the surface and away from any person, vessel, vehicle, or structure in noncongested areas. See 14 C.F.R. § 91.119(c). Section 91.119(d) allows for a helicopter to operate at less 

than those minimum altitudes when it can be operated "without hazard to persons or property on the 

surface," provided that "each person operating the helicopter complies with any routes or altitudes 

specifically prescribed for helicopters by the FAA."

An exemption is required because the proposed SC-UAS operations will normally need to occur 

below 400 feet AGL. In circumstances where the SC-UAS is used to inspect a structure whose height 

exceeds 400 feet AGL, the SC-UAS will not be operated more than 100 feet above the highest point on

the structure, and within 100 feet horizontally of the structure. Additionally, due the nature of the proposed

operations, the Pilot and/or Observers(s) may need to be less than 500 feet away from the UAS.

15Relief from § 91.119(a) will not be necessary because Petitioner will be able to perform an emergency 

landing without undue hazard to persons or property on the ground in the event of a failure. Petitioner's 

proposed UAS operations will not occur over congested areas, and therefore an exemption from §

91.119(b) will not be necessary. See e.g., Grant of Exemption No. 11157 to Slug wear, Inc., dba Like on a 

tree Aerial (FAA-2014-0534 at 15)
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Aug 13th, 2015

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Equivalent Level of Safety

Compared to flight operations with rotorcraft weighing far more than the maximum weights 

proposed herein, and given the lack of flammable fuel with the SC-UASs, any risk associated with these 

operations is far less than those that presently exist with conventional aircraft. An equivalent level of 

safety will be achieved given the size, weight, and speed of the SC-UASs, as well the controlled location 

where the operations will occur. In order to avoid any risk to manned aircraft, flight operations will be 

restricted to 400 feet AGL or below, or when inspecting a structure whose height exceeds 400 feet AGL, 

within 100 feet above the highest point on that structure and 100 feet horizontally of the structure.

As set forth in the Operations Manuals, the SC-UASs will be operated in a restricted area, and all 

flights will be operated at a lateral distance of at least 500 feet from any nonparticipating persons, unless 

that person is in a position where he or she is shielded from the SC-UAS and any possible debris resulting 

from SC-UAS failure. As required by the Operations Manuals, flights will be terminated if a 

nonparticipating person within 500 feet of the SC-UAS leaves a shielded position. Further, SC-UAS

operations will occur at least 500 feet away from vehicles or structures unless the property owner/controller 

has granted permission and the PIC has made a safety assessment of the risk of operating closer to those 

objects and, operations near the PIC or Observer will not present an undue hazard per § 91.119(a). 

Adherence to these restrictions in the elevation of the departure airport or barometric pressure. An 

exemption is required to the extent that the SC-UASs do not have a barometric altimeter, but rather a

GPS altitude read out. Sky and City’s Operations Manuals will ensure operations can be conducted

without compromising safety.

16

K. 14 C.F.R. § 91.121: Altimeter Settings

Sky and City seeks an exemption from 14 C.F.R. § 91.121, which requires a person operating an 

aircraft to maintain cruising altitude or flight level by reference to an altimeter that is set to the elevation of

the departure airport or barometric pressure An exemption is required to the extent that the SC-UASs do not

have a barometric altimeter, but rather a GPS altitude read out.

16See e.g., Grant of Exemption No. 11138 to Douglas Trudeau (FAA-2014-0481 at 19):

"If barriers or structures are present that can sufficiently protect nonparticipating persons from the UA or 

debris in the event of an accident, then the UA may operate closer than 500 feet to persons afforded such 

protection. The operator must also ensure that nonparticipating persons remain under such protection. If a 

situation arises where nonparticipating persons leave such protection and are within 500 feet of the UA, 

flight operations must cease immediately. When considering how to immediately cease operations, the 

primary concern is the safety of those nonparticipating persons. In addition, the FAA finds that operations 

may be conducted closer than 500 feet to vessels, vehicles and structures when the owner/controller of any 

such vessels, vehicles orstructures grants permission for the operation and the PIC makes a safety 

assessment of the risk of operating closer to those objects and determines that it does not present an undue 

hazard.”
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Equivalent Level of Safety

The FAA has stated that an equivalent level of safety to the requirements of 14 C.F.R. § 91.121 can be 

achieved in circumstances where: (1) the SC-UASs will be operated below 400 feet AGL or below17, (2) 

within VLOS, (3) where GPS based altitude information is relayed in real time to the operator at a groundbased on-screen display and, (4) where prior to each flight, a zero altitude initiation point is established for 

the PIC to confirm accuracy of the onboard GPS.

18

The SC-UASs that Sky and City intends to use for the proposed operations will meet all these 

operational characteristics. Moreover, as required by Sky and City’s Operations Manuals, the PIC will be 

required to calibrate the aircraft's GPS compass prior to each flight operation. Like prior FAA Section 333

Grants of Exemption, the SC-UASs Sky and City intends to use, and the safety mitigation procedures 

contained in the Operations Manuals, both ensure that an equivalent level of safety will be achieved, and a 

Grant of Exemption to the requirements of § 191.121 is therefore appropriate.

L. 14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions

Sky and City requests an exemption from 14 C.F.R. § 91.151(a)'s fuel requirements for flight in VFR

conditions. Section 91.151 states:

(a) No person may begin a flight in an airplane under VFR conditions unless (considering wind and 

forecast weather conditions) there is enough fuel to fly to the first point of intended landing and, 

assuming normal cruising speed –

(1) During the day, to fly after that for at least 30 minutes;

or

(2) At night, to fly after that for at least 45 minutes.

Here, the technological limitations on SC-UAS battery power means that no meaningful flight 

operations can be conducted while still maintaining a 30-minute battery reserve. An exemption from the 

fuel requirements of 14 C.F.R. § 91.151(a) is therefore required.

17

If the height of the structure being inspected exceeds 400 feet AGL, the SC-UAS will not be operated 

more than 100 feet above the highest point on the structure.

18

See Grant of Exemption No. 11062 to Astraeus Aerial (FAA-2014-0352 at 21).
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Page 22

In the Grant of Exemption to VDOS (Exemption No. 11112), the FAA determined that an 

equivalent level of safety to the fuel requirements for flight in VFR conditions could be achieved by 

prohibiting the PIC from beginning a SC-UAS flight unless (considering wind and forecast weather 

conditions) there was enough power to fly to the first intended point of landing and, assuming normal 

cruising speed, to fly after that for at least 10 minutes.

In reaching this conclusion, the FAA considered that the SC-UAS batteries for the SC-UAS

provided provide approximately 20 minutes of powered flight (with payload) and provided battery level 

and battery time remaining in minutes and seconds to the PIC.

19 The FAA also considered the fact that the

SC-UAS operating manual states: “start every flight with a fully charged battery in the aerial vehicle”, and 

that in the event that the SC-UAS should run low on power, the PIC will be alerted and can land the SCUAS as soon as possible. Like the VDOS Grant of Exemption, Sky and City use of the SC-UAS, combined 

with the requirements of Petitioner's Operations Manuals, ensure that an equivalent level of safety can be 

achieved.

Similarly, in the Grant of Exemption to Alan Purwin (Exemption No. 11161), the FAA determined 

that an equivalent level of safety to the fuel requirements for flight in VFR conditions could be achieved by 

prohibiting the PIC from beginning a flight with the SC-UAS unless (considering wind and forecast 

weather conditions), there was enough power to fly at normal cruising speed to the intended landing point 

and land the UA with 25% battery power remaining. Sky and City will adhere to this limitation for SCUAS flights.

The SC-UAS includes a low battery warning system and the amount of battery reserve power 

remaining is transmitted to the PIC via telemetric data feed, which downlinks from the SC-UAS to a 

ground-based-on-screen display.

20 As required by Sky and City’s Operations Manuals, the PIC will

promptly fly the SC-UAS back to the home launch location or pre-determined abort location where the

SC-UAS may safely land, while still maintaining a minimum of 25% reserve battery power. Sky and City

submits that the procedures requiring flights to be safely terminated once the batteries fall below 25%

capacity, combined with the requirement that flights only be conducted within a secure, isolated area, using

a HuP- UAS weighting less than 25 pounds, and within VLOS of the PIC and Observer(s), ensure that the 

proposed operation will provide an equivalent or higher level of safety to that provided by the regulations 

from which exemption is sought.

19 Grant of Exemption No. 11112 to VDOS Global, LLC (FAA-2014-0382 at 10).

20 The UAS ground control station displays, the UASs position, navigation route, tail number, altitude, 

heading, north seeking arrow, range to targets, calculated target position, date/time, and sensor heading and 

orientation relative to the UAS.
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Page 23

VI. DRUG AND ALCOHOL PROGRAM

The Sky and City will have policies in place to ensure that no person may participate in SC-UAS

flight operations if they are under the influence of alcohol or any drug.

VII. PUBLIC INTEREST

The public interest will be served by granting Sky and City’s Petition for Exemption. Congress 

has established a national policy that favors early integration of SC-UAS into the NAS in controlled, safe 

working environments such as those proposed in this Petition. Granting this Petition for Exemption helps 

fulfill Congress' goal in passing Section 333(a) through (c) of the Reform Act—the FAA Administrator's 

assessment of whether certain SC-UAS may operate safely in the NAS before completion of the 

statutorily required rulemaking.

The proposed SC-UAS operations in this Petition for Exemption significantly improve safety and 

reduce risk, harm or serious injury to real estate inspectors and property assessors. Traditional methods of 

real estate video production and inspection of structures, expose videographer-inspectors to higher risks of 

serious injuries, or death. Videographer-inspectors need to climb roof tops or otherwise perform elevated 

work, which exposes them to the risk of dangerous falls, electrocution or other work related extremes. In 

addition, depending on the nature of the video needed and the inspection work, proximity to equipment and 

other hazards associated with industrial real estate sites and real estate construction locations often involves 

a great deal of risk to accomplish the job. The use of SC-UASs mitigates these hazards and is ultimately a

much safer method of performing these and most other types of inspections.

The use of small SC-UASs also enhances safety and reduces risk because, unlike manned aircraft 

weighing thousands of pounds, carrying crew in addition to flammable fuel, the SC-UASs carry no 

passengers or crew. Further, in the unlikely event of an accident, the Sky and City small battery powered 

SC-UASs presents significantly less danger to persons on the ground when compared to operations by

conventional manned aircraft.

21 As Petitioner's SC-UASs are battery powered, the public will also benefit

from a reduction in harmful emissions associated with conventional aircraft performing in the same 

functions proposed herein. Lastly, as recognized by the FAA in prior Section 333 Grants of Exemption to 

filmmakers, SC-UASs provide an additional tool for the aerial filming industry, adding a greater degree 

of flexibility, which supplements the current capabilities offered by manned aircraft.

22

 __________________________

21 See Grant of Exemption No. 11158 to Team 5, LLC (FAA-2014-0783 at 12):

"Manned helicopters conducting aerial filming can weigh 6,000 pounds or more and are operated by an 

onboard pilot, in addition to other onboard crewmembers, as necessary. The petitioner’s SC-UAS will 

weigh less than 55 pounds with no onboard pilot or crew. The pilot and crew will be remotely located from 

the aircraft. The limited weight significantly reduces the potential for harm to participating and 

nonparticipating individuals or property in the event of an incident or accident. The risk to an onboard pilot 

and crew during an incident or accident is eliminated with the use of a UA for the aerial filming operation."
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VIII. PRIVACY

All Sky and City SC-UAS operations will be conducted in accordance with applicable federal, 

state, or local laws regarding privacy. All operations shall be conducted over private or controlled-access

property with permission from the land owner/controller or authorized representative. Permission from land

owner/controller or authorized representative will be obtained for each flight to be conducted.

IX. FEDERAL REGISTER SUMMARY

Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication in the FEDERAL 

REGISTER, should it be determined that publication is needed:

Petitioner seeks an exemption from the following rules in Title 14 of the Code of Federal Regulations: 

Part 21, Subpart H; Part 27; 45.23(b); 45.27(a); 61.113; 91.7(a); 91.9(b)(2); 91.9(c); 91.103; 91.109(a);

91.119(c); 91.121; 91.151(a); 91.203 (a) & (b); 91.405(a); 91.407(a)(1); 91.409(a)(1) & (2); 91.417 (a) &

(b).

The exemption will enhance the quality of real estate video capture that could never be performed 

by conventional aircraft and increases safety and greatly reduces risk to real estate videographers and 

inspectors. Additionally reduces the danger to onsite employees, the public and property owners from the 

substantial hazards associated with performing equivalent aerial videography, photography and inspection 

of real estate property with conventional fixed-wing aircraft, rotorcraft, or other methods.

X. CONCLUSION

The Sky and City Petition for Exemption satisfies the criteria articulated in Section 333 of the 

Reform Act of 2012 including weight, speed, operating capabilities, proximity to airports and populated 

areas, operation within VLOS and national security. The proposed SC-UAS operations will reduce the 

inherent dangers and risks of real estate inspectors and property assessors that currently use scaffolding and 

ladders. Additionally, SC-UAS operations will benefit the public as a whole improving safety and reducing 

risk by the elimination of conventional aircraft alleviating human exposure to danger. In consideration of 

the foregoing, this Petition for Exemption provides the FAA with more than adequate justification for 

granting the requested exemptions allowing Sky and City to use small SC-UASs for aerial videography,

photography, surveying, mapping and inspection services for residential, commercial, industrial and 

government real estate property services.

22 See e.g., Grant of Exemption No. 11178 to Picture Factory, Inc. (FAA-2014-0794 at 18).
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Page 25

We thank you for your prompt consideration of our requested exemptions. 

Respectfully Submitted,

Carll Alvarado

City Limits, Inc.

12653 Osborne Street

Pacoima, CA, 91331

Should you have any questions, or if you need any additional information to support the requested 

exemptions, please contact the undersigned at:

City Limits, Inc.

Phone: (718)-213-3069

Email: dezalvarado@gmail.com

(The following attached items contain proprietary and commercial information exempt from disclosure 

under the Freedom of Information Act, 5 U.S.C. § 522 et seq., and should be held in a separate file pursuant 

to 14 C.F.R. § 11.35(b)).

Attachments:

1. General Operations Manual

2. PIC Operating Manual

3. Company Protocols

4. Location Protocols

5. Flight Communications Protocols

6. Departing Location Protocols

7. Transmitter Protocols

8. Preflight Checklist

9. Post Flight Checklist

10. Equipment Checklist

11. UAS Manufacturer’s Manuals

a. User Manuals

b. UAS Maintenance Manuals